Knapp v. Commissioner
United States Tax Court
Tuition payments were made by P's employer, NYU Law School, on behalf of P's children directly to the educational institutions they attended. Held: These payments are not scholarships under sec. 117, I.R.C. 1954, and are taxable compensation to petitioner. Held, further, the Court does not have jurisdiction to enforce the fringe benefit moratorium.
1Opinion of the Court
PARR, Judge:
Respondent determined a deficiency in petitioners’ 1979 Federal income tax in the amount of $5,218.50, and an addition to their 1979 Federal income tax in the amount of $260.93 pursuant to section 6653(a).1 After concessions, the issue for decision is whether Charles L. Knapp (petitioner) received taxable compensation from his employer, New York University School of Law (the law school), in the form of tuition payments made by the law school’s Law Center Foundation (LCF) on behalf of petitioner’s daughters directly to the educational institutions they attended. In support of their…
2Cases cited19 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. CartwrightSupreme Court of the United States · 1973
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Colorado National Bank v. CommissionerSupreme Court of the United States · 1938
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3Cited by18 opinions
- Woods v. CommissionerUnited States Tax Court · 1989
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- CSI Hydrostatic Testers v. CommissionerUnited States Tax Court · 1994
- Martin v. CommissionerUnited States Tax Court · 1991
- Estate of D'Ambrosio v. CommissionerUnited States Tax Court · 1995
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